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HMRC internal manual

Enquiry Manual

Working the Enquiry: Closure Applications: Following Contact with the Taxpayer

Contacting the taxpayer at any time during the course of the enquiry including

  • an informal request for further information, either in writing, on the telephone or at a meeting
  • a request for a meeting
  • a request to visit premises

may lead to a closure application. In any of these circumstances you should

  • attempt to convince the taxpayer and agent of your need to continue the enquiry and
  • ask them to withdraw the closure application in writing.

Where disputes do arise you should consider whether Alternative Dispute Resolution (ADR) may help you and the taxpayer resolve these before the taxpayer applies to a tribunal for a closure notice. See the ADR web pages for guidance about ADR.

But if the application is maintained you must

  • be prepared to contest it, and
  • follow the guidance at EM1990 where the tribunal gives a direction.